ML20113B603

Forwards App R Reevaluation,Interim Compensatory Measures & Exemption Requests. at Present Stage of Reverification of Fire Protection Program,No Major Redesign of Safe Shutdown Paths or Philosophy Necessary

ML20113B603
Person / Time
Site:	Quad Cities
Issue date:	12/18/1984
From:	Rybak B COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20113B605	List: ML20113B603
References
9533N, NUDOCS 8504110291
Download: ML20113B603 (3)

Text

r Commonwealth Edison

> One First N= tion

1 PI:2e, Chicrgo. Ilhnois AddrDss R ply to: Post Office Box 767 .

X / Chicago Illinois 60690 December 18, 1984 i

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Quad Cities Station Units 1 and 2 Submittal of Appendix R Reverification Results NRC Docket Nos. 50-254 and 50-265 References (a): D. B. Vassallo letter to L. O.

DelGeorge dated December 30, 1982.

(b): B. Rybak letter to H. R. Denton dated May 18, 1983.

(c): B. Rybak letter to H. R. Denton dated December 23, 1983.

(d): B. Rybak letter to H. R. Denton dated March 30, 1984.

Dear Mr. Denton:

In reference (c), Commonwealth Edison (CECO) notified the NRC that, because of recent NRC clarifications of Appendix R requirements, an independent review of the Quad Cities Station Units 1 and 2 fire protection program was initiated. CECO met with members of your staf f on October 16, to present the hot shutdown portion of this review and committed to a formal submittal of the results in December 1984.

Our reverification program is essentially completed; some minor work is still left in the areas of spurious' operation, cold shutdown, emergency lighting, exposed structural steel, and NFPA Code reviews, but we believe there are no major concerns in any of these areas. Enclosure I is a summary of the reverification methodology and status. At this stage of our reverification we have found that no major redesign of safe shutdown paths or philosophy is necessitated, and the reverification has not adversely affected previously identified modifications (References (b) and (d)).

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.H. R. Denton .

December 18, 1984 The additional modifications now deemed necessary (see Table 2 of Enclosure II) consist mainly of additional suppression and detection and the upgrading of some fire barriers. The completion of these additional modifications is not constrained by any refueling outage. A completion schedule for them has not been established, however, because we are still completing the necessary engineering work and determining procurement and installation requirements. As for the previously identified modifications, their projected completion dates are as shown in Table 1 of Enclosure II.

We will update you on the status of the schedule for both the previous and new modifications by the week of February 25, 1985.

The schedular requirements for Appendix R modifications are outlined in 10 CFR 50.48. In reference (b), CECO requested schedular exemptions for the previously identified modifications, since we were unable to meet those schedular requirements. Similarly, the schedular requirements cannot be met for the newly identified modifications.

Consequently, CECO is also requesting schedular exemptions for these additional modifications. The interim compensatory measures for all of the modifications which cannot be completed within the schedular requirements of the rule are detailed in Table 2 of Enclosure 2. These interim measures have been initiated where necessary to provide an cdditional level of protection until completion of the modifications, and they will be discontinued as the modifications which established their need are completed.

Our exemption requests are found in Enclosure III. These exemption requests fall into two general categories - (1) the lack of complete 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers and (2) the lack of detection and suppression throughout the fire areas. We believe these exemption requests are prudent and justifiable and request your approval of them.

Commonwealth Edison believes this reverification effort demonstrates safely shutdown.

that in the case of a fire the affected unit or units can be The additional modifications and exemption requests are needed to meet the literal requirement of Appendix R. Enclosure II cntitled " Interim Compensatory Measures" identifies the need for additional modifications and verifies that the plant, as originally modified to meet Appendix R, provides a level of protection sufficient to allow for a reasonable completion schedule for all of the remaining Appendix R work.

Although we feel our reverification efforts are thorough tnd complete, CECO is committed to a continuing evaluation of all the safe shutdown systems and equipment to meet the requirements of Appendix R.

Therefore, future compliance measures or exemptions may be necessary as a result of new pinnt modifications.

L

H. R. Denton .

December 18, 1984 Please address any. questions you may have regarding this matter to this office.

One. signed original and forty (40) copies of this letter are provided for your~use. Due to the size and nature of the enclosures, only ten (10) copies are provided.

Very truly yours,

/S.

B. Ryba k

Nuclear Licensing A nistrator im cc: R. Bevan - NRR (w/o encl.)

NRC Resident Inspector - Quad Cities (w/o encl.)

Enclosure 9533N